Transcript for Public Hearing of September 22,...

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Commission canadienne de sûreté nucléaire Audience publique Le 22 septembre 2016 Salle des audiences publiques 14 e étage 280, rue Slater Ottawa (Ontario) Commissaires présents M. Michael Binder M. Dan Tolgyesi D r Sandy McEwan M me Rumina Velshi M. André Harvey Secrétaire: M. Marc Leblanc Avocate générale : M e Lisa Thiele Canadian Nuclear Safety Commission Public hearing September 22 nd , 2016 Public Hearing Room 14 th floor 280 Slater Street Ottawa, Ontario Commission Members present Dr. Michael Binder Mr. Dan Tolgyesi Dr. Sandy McEwan Ms Rumina Velshi Mr. André Harvey Secretary: Mr. Marc Leblanc General Counsel: Ms Lisa Thiele 613-521-0703 StenoTran www.stenotran.com

Transcript of Transcript for Public Hearing of September 22,...

  • Commission canadienne de sûreté nucléaire

    Audience publique

    Le 22 septembre 2016

    Salle des audiences publiques 14e étage 280, rue Slater Ottawa (Ontario)

    Commissaires présents

    M. Michael Binder M. Dan Tolgyesi Dr Sandy McEwan Mme Rumina Velshi M. André Harvey

    Secrétaire:

    M. Marc Leblanc

    Avocate générale :

    Me Lisa Thiele

    Canadian Nuclear Safety Commission Public hearing September 22nd, 2016 Public Hearing Room 14th floor 280 Slater Street Ottawa, Ontario Commission Members present Dr. Michael Binder Mr. Dan Tolgyesi Dr. Sandy McEwan Ms Rumina Velshi Mr. André Harvey Secretary: Mr. Marc Leblanc General Counsel: Ms Lisa Thiele

    613-521-0703 StenoTran www.stenotran.com

    http:www.stenotran.com

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    TABLE OF CONTENTS PAGE

    CMD 16 H5.A 1 Opening Remarks CMD 16-H6.1/16-H6.1A 5 Oral presentation bySaskatchewan Research Council CMD 16-H6/16-H6.A 26 Oral presentation by CNSC staff CMD 16-H6.2 39 Written submission from Saskatchewan Environmental Society CMD 16-H6.3 62 Written submission from Prince Albert Grand Council

    http:16-H6.1/16-H6.1A

  • Ottawa, Ontario / Ottawa (Ontario) --- Upon commencing on Thursday, September 22, 2016 at 1:18

    p.m. / L'audience débute le jeudi

    22 septembre 2016 à 13 h 18

    CMD 16-H5.A Opening Remarks M. LEBLANC : Bonjour, Mesdames et Messieurs. Bienvenue à cette audience publique de la Commission canadienne de sûreté nucléaire. The public hearing is regarding the request from the Saskatchewan Research Council, or SRC, to remove the hold point for Phase 2 of the Gunnar Remediation Project. During today's business, we have simultaneous interpretation. Des appareils pour l’interprétation sont disponibles à la réception. La version française est au poste 2 and the English version is on channel 1. We would ask that you please keep the pace of your speech relatively slow so that the interpreters have a chance to keep up. Les transcriptions seront disponibles sur le site Web de la Commission dès la semaine prochaine. And

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    to make those transcripts as meaningful as possible, we would ask everyone to identify themselves before speaking.

    I’d also like to note that this proceeding is being video webcast live and that the proceeding is also archived on our website for a three-month period after the close of the hearing.

    As a courtesy to others in the room, I would ask that you please silence your cell phones and other electronic devices.

    Monsieur Binder, président et premier dirigeant de la CCSN, va présider cette audience publique. Mr. President.

    THE PRESIDENT: Thank you, Marc. Good afternoon, and welcome to the public hearing of the Canadian Nuclear Safety Commission.

    Mon nom est Michael Binder. Je suis le président de la Commission canadienne de sûreté nucléaire.

    Je souhaite la bienvenue aux gens ici présents and welcome to all of you who are joining us through the webcast.

    I'd like to start by introducing the Members of the Commission.

    On my right is Monsieur Dan Tolgyesi; on my left are Dr. Sandy McEwan, Ms Rumina Velshi and Monsieur André Harvey.

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    We already heard from our Secretary, Marc Leblanc.

    We also have with us here today, Ms Lisa Thiele, Senior General Counsel to the Commission.

    I would now like to call for the adoption of the agenda by the Commission Members, as outlined in Commission Member Document 16-H5.A.

    Do I have concurrence? For the record, the agenda is adopted.

    Marc...? MR. LEBLANC: The Notice of Public Hearing

    2016-H-04 was published on June 24th of this year. The submission from the Saskatchewan

    Research Council (SRC) and the recommendations from CNSC staff were filed on July 22, 2016.

    The public was invited to participate by way of written submissions. August 22nd was the deadline set for filing by intervenors. The Commission received two submissions.

    September 14th was the deadline for filing of supplementary information and presentations and I note that presentations were filed by SRC and CNSC staff.

    The way things will work today is that we will begin with the presentations by SRC followed by the CNSC staff and then we will proceed immediately with the

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    review of the written submissions filed by the intervenors and questions pertaining to those interventions and then will be followed by general rounds of questions. Mr. President...?

    THE PRESIDENT: Thank you. Before we proceed with the presentation on SRC's request, I would like to recognize some people and check technology if it works.

    So first of all, I understand that joining us via teleconference is Dr. James Irvine. Can you hear us?

    DR. IRVINE: Yes, we can hear you well. Thank you.

    THE PRESIDENT: And we also have Mr. George Bihun -- I'm not sure I pronounced it correctly --from Ministry of Environment of Saskatchewan. Can you hear us?

    MR. BIHUN: Yes, I can. I can hear you. Thank you.

    THE PRESIDENT: Okay, thank you. And there are also people from SRC we should only introduce, I guess, as part of your opening remarks.

    Am I missing anybody? Okay. We will see once you introduce them.

  • CMD 16-H6.1/16-H6.1A Oral presentation by Saskatchewan Research Council THE PRESIDENT: Okay. So let's start by calling for the presentation from Saskatchewan Research Council as outlined in Commission Member Documents 16-H6.1 and 16-H6.1A. I understand that you, Mr. Muldoon, will make the presentation. The floor is yours. MR. MULDOON: Good afternoon. For the record my name is Joe Muldoon from Saskatchewan Research Council. I am the Vice-President of the Environment Division at SRC. I have with me today: - the Manager of the Environmental Remediation Program, Ian Wilson; - the Chief Scientist for the project Alexey Klyashtorin, behind me to my left; - Skye Ketilson, the Gunnar Other Site Aspects Project Manager, behind me to my right; - Mark Calette, Senior Advisor for Community and Aboriginal Engagement, behind me; - Mark Liskowich, Principal Consultant, to my right, far right, and Trevor Podaima, Senior Consultant,

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    http:16-H6.1Ahttp:16-H6.1/16-H6.1A

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    both of which, Mark and Trevor are our design consultants, SRK.

    To my left, I have Cory Hughes, Executive Director of Mineral Policy for the Saskatchewan Ministry of the Economy.

    So I will just start the presentation. As you know, SRC is here today applying

    for a licence hold point release for the Gunnar Other Site Aspects Remediation Activities. The release of this hold point will allow SRC to begin final planning and procurement processes for this work and, most importantly, allow this component of the remediation activities to be integrated with the tailings-covered construction already started.

    This will result in a much more holistic approach to cite remediation and allow a more effective and efficient project implementation.

    The purpose of the Gunnar project is to reduce the safety and environmental risks that the site poses to the public utilizing sustainable remediation options that are both technically and economically feasible. It's also to implement a long-term environmental monitoring program and minimize long term care and maintenance at the site as part of the eventual entry of the site into the provincial institutional controls

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    program. Both the requirement and benefit of the

    Gunnar Project has been the development of a meaningful engagement strategy with local community members over the course of the project.

    As stated in the Gunnar Environmental Impact Statement, SRC understands that it has a duty to consult with local Aboriginal community members about possible effects of the remediation project. Based on feedback from industry, Aboriginal communities and government, we feel that SRC has a leading engagement strategy in place for its legacy mine and remediation projects.

    We will present a short video at the end of this presentation which covers the last community visit to the Gunnar site in August of this year.

    This slide provides a brief update of what has happened with the Gunnar tailing project since the hold point was removed last year. So the tailings remediation hold point was removed in December 2015. We have completed the detailed remediation design report. We have awarded through procurement the remediation contract to a Fond-du-Lac Nuna and joint venture, Fond-du-Lac First Nations being found within the Athabascan Basin.

    And we have started site preparation

  • initiation in September of this year. We are underway with that as we speak and we are -- we will begin the full remediation operation where we will really get into the bulk of the work in the spring of 2017. I will now turn the detailed description of the project over to Ian Wilson, the Manager of the Environmental Remediation Program at Saskatchewan Research Council. MR. WILSON: For the record, my name is Ian Wilson. To facilitate SRC's project management and corresponding with the CNSC licence structure, the Gunnar site has been divided into the tailings and the other aspects. For clarity, the remainder of this presentation will focus on the other aspects with a goal of removing the licence hold point. The other site aspects are defined as: - Non-contaminated demolition debris which consists of asbestos-containing materials, steel, wood and concrete; contaminated and hazardous materials which consists of hydrocarbon-contaminated soil and rock; treated wood and PH-impacted material, waste rock; - The general site which consists of three mine openings; catchment-3 drainage, incidental site debris and areas of gamma over the objective levels and the water-filled open pit.

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  • The specific objectives of the Gunnar Other Site Aspects Project are: - The stabilization of waste rock piles to minimize human health risks posed to by the gamma radiation and the slope instabilities; - Minimize of contaminant releases from the tailings and waste rock to Lake Athabasca; - Permanent disposal of all waste materials in a manner that is environmentally sound and meets regulatory requirements; - Remediation and re-contouring of the landscape in a manner that is compliant with the natural surrounding and future use of the site; - And taking measures to ensure conventional health and safety. The major sources of risk to public safety and the environment that the Other Site Aspects currently contain are physical hazards; for example, waste rock slopes, metal debris and access to the underground; exposure to radiation found on waste rock and mill debris, exposure to chemical contamination found in waste rock, remaining mill process chemicals in the acid plant area and potential exposure to asbestos-containing materials. The remediation objectives for the Other Site Aspects Project, as taken from the EIS, is the long

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    term mitigation of residual public safety and environmental health risks applied to radiation exposure, water and air quality.

    To specifically meet these objectives a remediation plan has been developed to:

    - One, consolidate and permanently dispose of the non-hazardous demolition debris;

    - Two, consolidate and permanently dispose of contaminated rock and debris;

    - Three, stabilize waste rock slopes; - Four, reduce gamma exposure through use

    of an engineered cover; - Five, minimize contaminant loading to

    St. Mary's Channel in Zeemel Bay; - And six, monitor the site to ensure

    public and environmental safety during and after the remediation work.

    Remedial options were generated through the decision tree process of the EIS, through consultation with community members during meetings and workshops and by reviewing input from regulatory authorities.

    Remedial options were evaluated using a number of facets including safety which is the number one priority on this project; the decision tree from the EIS which you have seen before during previous Commission

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    hearings; multiple accounts analysis which is a quantitative process that assigns numeric values to options based on risk, adaptive management cost and public perception, and input from local community members.

    From the evaluation of all options, preferred options have been identified for each site aspect and will be presented in subsequent slides.

    For the non-contaminated demolition debris which is marked in blue and consists of asbestos, steel, concrete and wood, the preferred option is to construct an onsite landfill in the mill and acid plant area, as marked in yellow. The landfill will be constructed in accordance with Saskatchewan Ministry of Environment Regulations, classified as Type I waste, and house approximately 99,000 cubic metres of asbestos, steel, concrete, wood waste.

    The advantages of this remedial option are: A low risk of differential sediment, low permeable nature of the bedrock floor, good public perception ranking, situated away from Zeemel and St. Mary's Channel, the shortest haul distance which equates to the lowest cost and allows for flexibility in unforeseen events and adaptive management.

    The execution of this landfill will be to haul and place demolition debris on a prepared landfill base covered with approximately 19,000 cubic metres of

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    concrete and followed by a 0.5 metre thick cover of clean, locally-sourced aggregate.

    For the contaminated and hazardous materials which are marked in red, the preferred plan is to excavate the acid plant material which is PH-impacted and haul to the tailings area while the remaining material consisting of approximately 4,000 cubic metres of hydrocarbon-impacted soil and rock and contaminated wood will be consolidated into one landfill marked in yellow.

    The landfill will be constructed in accordance with Saskatchewan Ministry of Environment Regulations classified as Type II waste and be a dry tune concept built on competent bedrock floor. The advantages of this remedial option are utilizing existing bedrock foundation; good public perception situated away from Zeemel Bay and St. Mary's Channel. It is the shortest haul distance and allows for the maximum flexibility for unseen events.

    The execution plan for this landfill will be to excavate PH-impacted material and bury under the tailings cover; prepare the bedrock foundation for landfill base and cover with 1.2 m thick clean local aggregate.

    The remedial objective for the waste rock as taken from the EIS is to remove physical hazards to humans and wildlife, reduce gamma exposure, reduce human

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    health risks and reduce ecological risks from uranium loading.

    For the waste rock pile marked in green and grey the preferred remedial option is to re-establish the historic channel and grade; cover and revegetate the waste rock piles. The advantage of this option is it presents the least amount of risk compared to other options, allows for adaptive management, is highly favourable compared to the pit fill option due to the significant disadvantages of backfilling the pit discussed in later slides; more economic than other options.

    This option calls for the removal of approximately 851,000 cubic metres of waste rock overlying in an historic stream bed for integration into the tailings as grading material. The remaining waste rock pile will be re-sloped; drainage features installed and covered with 0.5 metres of local aggregate and revegetated.

    The waste rock underlying the former tank farm and camp will also be regraded.

    This slide shows the proposed post-remediation landfill and waste rock landforms. The landfill and waste rock slopes will be graded between 4:1 and 5:1. Micro-topography will be incorporated into the slopes to break and promote vegetation and reduce erosion.

    For the remaining general site items which

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    consists of openings to the underground, elevated gamma areas and additional incidental debris, the preferred remedial option is to cover the access to the underground with stainless steel caps, cover the elevated gamma areas with 0.5 metre of local aggregate and revegetate and remove incidence of debris and place into the appropriate onsite landfill.

    The advantages of this option is that the steel caps provide a strong, durable and easily fabricated and modified mechanism to prevent access to the underground, while the local aggregate cover provides radiation insulation, while eventually blending into the surrounding land forms.

    The remedial objectives for the open pit, as taken from the EIS, is to reduce human health risks, reduce ecological risks and provide structural stability, which it is now doing in its current form with the water.

    This animation shows the pit from an aerial photo vantage, with both the pit depth and the underground workings to scale.

    This animation shows a 3D rendering of the open pit and underlying mine workings. The animation will stop momentarily to align from the perspective of the previous slide.

    It should be noted that the pit is just a

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    surface expression of a much larger underground system that goes down 600 metres from surface.

    Also of note is the red oval in the pit, which is an approximation of the opening of the pit to the underground, scaled based on historic information.

    These animations were used successfully to convey information to community leaders who were very grateful for this form of visualization of historic information. --- Pause

    MR. WILSON: For the open pit, the preferred remediation option is to reduce loading to the pit by dealing with other site aspects and through the development of a monitoring plan to access the outcome of reduced loadings. The overriding advantage to this option is safety.

    Other options, including dewatering and infilling with waste rock, have an inherent risk to worker safety during implementation due to uncontrollable pit wall stability and subsidence of material from the pit to the underground.

    Other major advantages of this remedial option include no adverse effects on aquatic or terrestrial plant and animal populations, it allows for adaptive management in the future and a reduction in loading to the

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    pit from its current state in red to the proposed state in black.

    This table generalizes and shows all site aspects in its current condition when applied against the criteria from the EIS and the proposed preferred remedial options. As you can see, all the EIS criteria have been covered by the proposed remedial options presented today.

    During future implementation of the other sites aspect project, SRC will rely on its robust and field-tested project management approach, which consists of its corporate ISO 9000 2009 system, a site-specific management system which consists of programs and plans related to safety, radiation protection, environmental monitoring and protection, communications training and quality, and the execution plan, which includes project charter, governance, milestones, risk registry and management, management controls, performance management, quality management, financial controls, communications, consultation and engagement, environmental protection, safety, procurement, regulatory and resourcing tools.

    SRC also manages and maintains an 80-person camp onsite and the associated infrastructure that will be utilized for this project during implementation.

    SRC's anticipated forecasted timeline and

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    milestones for the other site aspects and tailings projects consist of remediation work between 2016 and 2022, post-remediation monitoring between 2022 and 2035, and entry into ICP after 2035.

    Since the start of Project CLEANS, SRC has conducted more than 135 formal meetings with community members.

    SRC continually communicates with community members and leadership through radio, print, our website, faxes, posters, fact sheets, teleconference, direct mail, email, text, Skype, Dene interpretation and Facebook.

    To provide a better framework for its interaction with the community representatives and leadership, SRC has conducted multiple site tours.

    As part of the previous Gunnar demolition and materials abatement activities, SRC and its contractors have conducted asbestos abatement training, safety training and radiation training.

    As part of SRC's management of Project CLEANS, it has expanded this training to include essential skills training, driver licence training, heavy equipment training, and will continue to expand its training programs following input directly from community members.

    Other ways in which SRC engages with

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    community members in the Athabasca Basin region includes through the Athabasca sector gathering, capacity and training initiatives partnered with the Prince Albert Grand Council, local site monitors providing independent site auditing, inclusion of community members on public procurement teams, SRC participant funding for its engagement events, which includes travel, accommodation and honorariums, local aboriginal labour inclusion which is greater than 50 percent in all of our projects, and presentations made during environmental quality community meetings.

    From feedback received from private industry, First Nations, government, SRC has been told that it has an industry leading community engagement strategy. As part of this strategy, SRC has pushed the boundaries of public procurement to maximize local involvement and sustainable development opportunities. As such, SRC has been nominated for both the Government of Saskatchewan Premier's Award of Excellence and the Canadian Public Procurement Council Achievement of Excellence in Procurement.

    SRC has developed and will continue to support a strong mutual relationship with the leadership and people of the Athabasca Basin region.

    Specific community engagement events that

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    have taken place to facilitate the creation of other site aspects remediation reporting includes hosting a workshop and submission of preliminary remediation design report for CNSC and public review in August of 2015, travel to Black Lake, Stony Rapids, Hatchet Lake and Wollaston, and Uranium City from December 1st to 4th, 2015 for community meetings, hosting a Gunnar Other Site Aspects Workshop in Saskatoon on April 26, 2016, hosting an onsite leadership tour of Gunnar Mine on August 22nd, 2016, and hosting the Gunnar Other Site Aspects Workshop in Saskatoon on August 23rd, 2016.

    SRC continues to work with community Elders from the region to integrate local plant knowledge into its revegetation strategy for Project CLEANS sites. This knowledge exchange is conducted in both the communities and at the sites themselves.

    In partnership with the Prince Albert Grand Council, SRC created and facilitated the Student Environmental Monitoring Project at the Gunnar site this summer. This program will be an ongoing mechanism for developing an awareness and spark for environmental sciences and engineering for local young people in the Athabasca Basin. It is hoped that working with our project partner, SRC can develop local expertise in the region to monitor the Gunnar and other remediated sites into the

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    future. I will now pass the presentation over to

    Joe Muldoon. MR. MULDOON: For the record, Joe Muldoon. Just before we close our presentation, I

    want to share a short video outlining community member comments from our last site visit in August of this year.

    When we hear community members describe the project and tell our story, we feel that our aboriginal community engagement activities have been successful. It is our intent, as mentioned already, to continue this dialogue with communities throughout the project.

    With your patience, I will also show a very short video -- these are always very short, videos are good -- I want to show a very short video that describes SRC's approach to meeting the challenge of managing the multiple data that is created with these kinds of projects and ensuring that this data is stored where it can be used now and be accessible into the future.

    As evidenced by some of the animations that we showed earlier, they were instrumental in terms of explaining to communities the impacts of working within the pit and why we wanted to go with the options that we have been before the Commission today.

    So this information, just the way that we

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    have been able to develop some of these geospatial applications has been very helpful.

    So I'm just going to move quickly to these two slides to show the community leaders first, the tour. --- Video presentation / Présentation vidéo

    "It was an abandoned mine that was just left. There was no long place to do any cleanup or anything like that, so nobody really pushed for a cleanup until now." "One of the main concerns of our people is the impacts of the contaminants that's in the water, that's in the land." "I'm not pleased about it, but what can one do, the damage has been done already. So with that, we can only assess the damage and hopefully one day it will be all cleaned up." "What you're walking on now is --this is the tailings." "With the tailings, I know -- I don't know how many football fields, it's massive. That's where they used to pump all the waste from the mine."

  • "As you can see, they're pretty fine

    and if you get a good wind, they can blow. After all the study that we have done over the years and talking with people in the area to cap these tailings using some of the material that's naturally available, the clean material, so anytime where the snow melts or anytime where there's a rainfall event, instead of going into the tailings themselves, picking up contaminants within the tailings and running back to the water, it's going to shed, just like a roof on your house is going to shed it."

    "There's three sections of the tailings and they're going to start tackling one at a time I guess send hopefully clean it up."

    "If it all works out, it will be great. It's, you know, shutting off the source of the contaminants going into the lake."

    "We're putting and designing an engineered landfill to place all the

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    material that you see around." "You see all that waste out there, all the metal and stuff like that, it's not going to be taken out of here, but they will put it in a place that you can contain it so that it's not scattered everywhere, which is good." "It's a positive step in terms of remediating and cleaning up the site. It's getting better every year. So hopefully with this project that's going to happen here, it will make it even safer, which will be really good." "Our people are going to be here long after any mine site that's in the region. We're not farmers, you know, we go out, our grocery store is out in the bush and out on the lake, so we want to make sure our land and our water is safe for future generations."

    --- Video presentation / Présentation vidéo "This brief presentation outlines

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    SRC's environmental data management system for site remediation.

    Data that is collected during site remediation work is usually spread across multiple documents and can be difficult to access. To help streamline this process, SRC developed a holistic environmental data management system which enables data to smoothly flow from its initial collection through the centralized data storage to project stakeholders. In the system, all data can be accessed through a web portal which doesn't require any specific technical skills.

    This map shows the former Gunnar mine site and can display locations where environmental samples were taken. The map features a dynamic legend and pop-up menus with additional information about each sample and its location.

    Users can view historical mining structures and wastes and access

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    historical and recent photos from certain vantage points to see how the site looked before remediation began and how it looks now.

    Gamma dose rate patterns can also be accessed and specific values can be viewed across the map.

    The web portal also allows you just to overlay aerial photos from different points in time. Users can swipe between images to compare them and the same can be done with historical drawings of the site.

    The system also incorporates underground data.

    This view shows the Gunnar mine's underground workings in scale with an aerial photo.

    SRC system also includes a 3-D model of the underground features and corresponding statistics.

    When it comes to reporting, data can be easily gathered in a pre-set reporting ready format within minutes.

  • Sample analytical data can also

    be easily gathered for a specific location, media or parameter.

    SRC's environmental data management system enables swift data processing and analysis and creates new opportunities to use data for well-informed decision-making."

    MR. MULDOON: And that concludes our presentation from Saskatchewan Research Council. THE PRESIDENT: Thank you. Thank you very much. --- Pause CMD 16-H6/16-H6.A Oral presentation by CNSC staff THE PRESIDENT: I would like to move to the presentation from CNSC staff as outlined in CMD 16-H6 and 16-H6.A. I understand -- who is going to make the presentation? Obviously, my notes here are not right. MS TADROS: I will, sir. Haidy Tadros, for the record. THE PRESIDENT: Okay. Please proceed.

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    MS TADROS: Thank you. Good afternoon, Mr. President, Members of

    the Commission. For the record, I am Haidy Tadros,

    Director General of the Directorate of Nuclear Cycle and Facilities Regulations.

    With me today to present this item are my colleagues, Ms Karine Glenn, Director of the Wastes and Decommissioning Division, and Dr. Karina Lange, Senior Project Officer also with the Wastes and Decommissioning Division.

    We are supported by several other colleague specialists here today who are available to address any comments you may have.

    The purpose of this presentation is to provide the Commission with CNSC staff's evaluation and recommendations regarding Saskatchewan Research Council's request to remove the hold point for Phase 2 of the Gunnar Remediation Project in order to allow for remediation of the entire Gunnar site.

    I will now turn the presentation over to Ms Glenn to provide information regarding the Gunnar Remediation Project and the Phase 2 hold point.

    MS GLENN: Good afternoon. For the record, my name is Karine Glenn.

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    The Saskatchewan Research Council, SRC, is carrying out the remediation of the Gunnar uranium mine and mill site, as authorized by the Commission in January 2015.

    In this presentation we will provide you with some history on the file and on the Phase 2 hold point, discuss CNSC staff's assessment of SRC's remediation plans for the site and provide a summary of aboriginal and public consultation. Finally, we will present CNSC staff's conclusions and recommendations.

    SRC is carrying out the remediation of the Gunnar site in three phases. The subject at this hearing is on SRC's request to the Commission to remove the regulatory hold point for Phase 2 of the Gunnar project. Phase 2 consists of carrying out remediation activities of the Gunnar site.

    The legacy Gunnar mine and mill site is located approximately 600 kilometres north of Saskatoon on the north shore of Lake Athabasca. The Gunnar mine began operations in 1955 and the site was shut down in 1964. The ownership of the site then reverted back to the Province of Saskatchewan.

    The Gunnar site consisted of open pit and underground mine workings, mining infrastructure, mine tailings deposits covering an area of over 70 hectares and waste rock piles. At the time of closure, the open pit and

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    underground workings were flooded and the mineshaft and associated openings were plugged with concrete.

    Federal oversight of the site did not begin until the year 2000 when the Nuclear Safety and Control Act came into effect. During the early 2000s, CNSC staff requested that the Saskatchewan Ministry of Environment improve the conditions of the site in accordance with the CNSC requirements.

    In 2006, the Saskatchewan provincial government signed a cost sharing agreement with the federal government and named SRC their agent for licensing and remediation of the site.

    To address the hazards associated with the ongoing deterioration of 50-year-old buildings onsite, the Commission issued SRC an order to bring down all the structures. This work was completed in 2011 and the order was closed.

    The purpose of the Gunnar project is to remediate the Gunnar site to a safe and stable state and, to the extent practicable, restore the environment, including land, water, air, fish and wildlife.

    The environmental assessment accepted by the Commission in 2015 defined specific objectives for the cleanup of the Gunnar site. SRC has already discussed these objectives in their presentation, so I will move

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    right away to the next slide. The remediation work is taking place in

    three main phases. Phase 1, which is now complete, consisted

    of site characterization and the development of the remediation plans for the various site components. Phase 2 consists of carrying out the actual remediation activities, and Phase 3 consists of long-term monitoring and maintenance, leading eventually to institutional control, which is currently scheduled to occur in approximately 2035.

    This slide shows a timeline that depicts the progress of the Gunnar Remediation Project starting in 2015 when the Commission first accepted the EA and issued SRC a licence with hold points for Phases 2 and 3.

    In November 2015, the Commission approved the partial removal of the Phase 2 hold point, allowing SRC to implement the remediation plans for the tailings area only.

    The subject of today's public hearing is on SRC's request to remove the remainder of that hold point to allow the remediation of the other site components.

    Interested aboriginal groups were invited to participate in all phases of the project review process, including both Phase 2 public proceedings.

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    The current licence for the site expires in 2025. At that time it is expected that the remediation activities will have been completed.

    SRC is required to request the Commission's approval prior to moving to Phase 3 of the project, which consists of maintenance and monitoring, and preparation for the transfer of the site to institutional controls.

    Following the November 2014 hearings for the Gunnar EA, the Commission in their record of proceedings requested that SRC develop plans for remediation of the different site components and present those plans at a public hearing with written interventions.

    Through the public hearing on September 30, 2015 for removal of the Phase 2 hold point -- for the partial removal of the Phase 2 hold point and today's proceedings, SRC has complied with the Commission's request.

    I will now turn the presentation over to Dr. Lange to discuss CNSC staff's technical review of the remediation plans and public consultation on the project.

    DR. LANGE: Dr. Karina Lange for the record.

    SRC is requesting the removal of the remainder of the hold point for Phase 2 of the Gunnar

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    Remediation Project. To satisfy conditions for removal of the hold point, SRC has submitted remediation plans, along with supporting information for the remaining site components in August 2015.

    Those plans were updated this year in 2016 in response to requests from CNSC staff, the Saskatchewan Ministry of Environment and local aboriginal communities. SRC posted their plans on their website as well as regular updates about the progress of the project.

    A community workshop on the remediation plans took place in Saskatoon in April of 2016 with CNSC, SRC and the Ministry of Saskatchewan. SRC continues to engage communities on the remediation plans, as you have seen in their presentation.

    SRC has completed Phase 1 work in January 2015 and this work has been completed in accordance with CNSC requirements.

    The Commission approved SRC to carry out remediation of the tailings area in November of 2015, and therefore the tailings area is not included in today's evaluation.

    Briefly, the tailings remediation plan consists of the construction of an engineered cover on the tailings area at the Gunnar site which totals more than 70 hectares in area.

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    CNSC staff have completed their review of SRC's remediation plans for the Gunnar waste rock piles, open pit and mine openings. The next few slides discuss CNSC staff's technical review.

    SRC's remediation plan for the waste rock piles consists of reducing the volume of waste rock by using it as tailings cover, grading the remaining waste rock piles to reduce the height and steep slopes, and then placing a 0.5 metre till cover that will be vegetated with native plant species on the surface of the waste rock. These activities are designed to meet the EA objectives to improve public safety, reduce radiation exposure, decrease infiltration into the waste rock and provide a vegetated landscape.

    SRC's remediation plan for the open pit consists of reducing contaminated water flowing into the pit and ensuring the continued isolation of the pit from Lake Athabasca by maintaining the rock barrier between the pit and the lake. These activities are designed to meet the EA objectives, to improve the water quality of the pit and to prevent contamination of Lake Athabasca.

    SRC's plan for the mine openings is to construct custom-designed engineered caps over the vent raise, mine shaft and back raise. These caps will be secured with bolts and grouting for long-term performance.

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    These activities are designed to meet the EA objectives to reduce public safety risks caused by unsecured mine openings.

    The Gunnar site also, as you saw in the previous presentation, has demolition debris such as wood, old pipes and equipment scattered around the site. Although the Commission has not requested the plans for demolition debris to be part of this public hearing, management of the debris is included in staff's CMD as cleanup of this debris will have a positive impact on improving safety of the site, along with general aesthetics.

    Cleanup of the demolition debris consists of reducing the volume, for example by cutting up larger pieces, and consolidating the majority of the waste into an onsite landfill that meets provincial requirements.

    CNSC staff's evaluation focused on geotechnical engineering, hydrology and contaminant transport as well as radiation exposure and long-term stability. Staff evaluated the remediation plans against the objectives outlined in the EA and for compliance with CNSC standards and regulations as well as with good engineering practices for similar legacy mine sites.

    Based on CNSC staff review, staff have concluded that the remediation plans for the remaining

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    Gunnar site components is complete, meets the objectives of the Gunnar Remediation Project Environmental Assessment and complies with CNSC regulatory requirements.

    Since the November 2015 Commission hearing, CNSC staff have carried out a number of consultation activities. These include:

    - providing a copy of the Commission's Record of Proceeding, including Reasons for Decision regarding the hearing to partially remove the hold point to allow for remediation of the tailings area;

    - staff participated in SRC's annual tour of Athabasca communities from November 30th to December 4th in the winter of 2015;

    - a letter was sent for information regarding the current Gunnar Remediation Project hearing on the removal of the remaining hold point;

    - the workshop was held in April 2016 with SRC, the Saskatchewan Ministry of Environment, which brought community representatives together to discuss the remediation plans for the site;

    - staff provided SRC's updated Gunnar Site Remediation Plan to communities for review and opportunities were provided to communities for written comments on the submission.

    The Joint Gunnar Remediation Options

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    Workshop that took place in April with SRC and the Saskatchewan Ministry of Environment was successful in bringing a large number of community representatives together to discuss SRC's remediation plans for the site.

    CNSC's participant funding program was used to facilitate this workshop and this funding was in addition to the funding that was previously awarded to the identified aboriginal groups to review SRC's remediation plans.

    The workshop was successful in meeting its intended goals. Community representatives provided valuable feedback on the Gunnar remediation plans directly to SRC and their engineering consultants.

    There was a lot of positive feedback on the progress of the project. However, there were still important concerns and questions raised by the community. These included the health of country foods, long-term monitoring and community involvement, incorporating traditional knowledge into remediation work, questions on the remediation plans themselves, scheduling and poor water quality around the site.

    In response, SRC has committed to addressing these concerns by incorporating comments into the design plans, such as contouring the waste rock piles and vegetating their surface with native plant species to

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    conform with the natural landscape, having Elders visit the site and provide knowledge and feedback on remediation activities and long-term monitoring, and by hosting community monitors at the site that can observe how communities are involved in the remediation and the long-term monitoring of the Gunnar site as well as the local region.

    CNSC awarded a one-time participant fund of $47,790 for the review of all of SRC's remediation plans and participation in both public hearings on SRC's requests related to the Phase 2 hold point. The deadline for applications was June 19, 2015.

    The Participant Funding Program granted funding to the following groups: Athabasca Chipewyan First Nation, Prince Albert Grand Council, Saskatchewan Environmental Society and Métis Nation Saskatchewan Northern Region 1.

    I will now hand the presentation back to Haidy Tadros to provide staff's conclusions and recommendations for the Phase 2 hold point.

    MS TADROS: Thank you. This is Haidy Tadros for the record. Based on CNSC staff's review of the

    information, we conclude that the remediation plans for the remaining Gunnar site components of the waste rock piles,

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    open pit, mine shaft and demolition debris comply with CNSC regulatory requirements and meet the objectives of the environmental assessment for the Gunnar Remediation Project.

    CNSC staff further conclude that SRC has carried out an effective aboriginal and public consultation program and that input from local communities is considered in the remediation plan.

    In summary, CNSC staff conclude that SRC has met the Commission's requirements for removal of the hold point for Phase 2 remediation activities.

    With that, CNSC staff recommend that the Commission consider removing the hold point for SRC to proceed with all Phase 2 remediation activities at the Gunnar site.

    CNSC staff will report annually to the Commission on the Gunnar Remediation Project as part of the regulatory oversight report on uranium mines, mills, and historic and decommissioned sites.

    Thank you and we are now available to address any comments.

  • CMD 16-H6.2 Written submission from Saskatchewan Environmental Society THE PRESIDENT: Thank you. Before we open the floor for questioning, as has been normal practice, we would like to deal first with the written interventions. The first submission is from Saskatchewan Environmental Society, as outlined in CMD 16-H6.2. Are there any questions from Commissioners? Who wants to start? Mr. Tolgyesi...? MEMBRE TOLGYESI : Merci, Monsieur le Président. On page 3 of the submission, Saskatchewan Environmental Society is saying that: "The Gunnar site necessitates a plan

    that offers a good expectation of remaining effective over many hundreds or thousands of years without human intervention. Given the nature of the wide distribution of contamination at the Gunnar site, such long-term stability would be

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    extremely difficult to provide." (As read)

    What are your projections regarding the period of future monitoring? How long should you go in the future?

    MR. WILSON: For the record, my name is Ian Wilson.

    I guess after the site has been put into the provincial Institutional Control Program, the program itself, there are mechanisms involved to monitor the site in perpetuity as well as funds set aside for maintenance. So I guess as an answer to that question, the Government of Saskatchewan will take back that site and monitor it over the course of its lifespan I guess.

    MEMBER TOLGYESI: Are there any funds or financial guarantees which should be constituted to perpetuate the monitoring?

    MR. HUGHES: Cory Hughes for the record. So when a site enters -- when it's

    released by the CNSC and the Saskatchewan Ministry of Environment to enter into the Institutional Control Program, there is funding required as part of the entry for the monitoring and maintenance and a schedule is devised. There's also an unforeseen events fund that would cover activities or circumstances outside of what was planned in

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    the decommissioning plan. Those funds are invested in the long term. There is a return on those, so those funds will grow over time.

    There is a financial assurance required initially to ensure that if something happens in the short term before the funds are sufficient that the responsible party, in this case the Government of Saskatchewan and our funding partner NRCan, would be responsible for that. But over time, those funds will grow and those sites will be monitored in perpetuity, as Mr. Wilson said, to ensure that funding is available and those sites will be monitored until the end of time right now is the plan.

    MEMBER TOLGYESI: Do you forecast that eventually this contamination and discharge will reduce to the level where it could be self-sustained and will not necessitate in the long term -- I'm not talking about five years, 10 years, but projection in the long term -- that it will self-sustain and not need anymore much more monitoring?

    MR. WILSON: The monitoring schedule will be adjusted over time, so I think that there would be input to that as to what the status of the project was over time. Right now we are not making projections that monitoring is going to end at a certain period, though.

    THE PRESIDENT: Just to follow up. Just

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    remind me again, in the unlikely event in which Saskatchewan reneges on the commitment, is CNSC able to get back and get involved if something happens? I mean this is a very hypothetical situation. It's not a one-way flow, is it? I mean from a regulatory perspective if there is a requirement to re-regulate, the CNSC has the mandate to do so, just to allay the hypothetical doomsday scenario that is being described here.

    MS GLENN: Karine Glenn for the record. The Commission grants an exemption based

    on the fact that there are appropriate institutional controls in place. That is the premise behind the release from CNSC oversight into the care of another body. Should that body no longer be there or no longer be in place, that site would then at that point still require a CNSC licence under current CNSC regulations.

    THE PRESIDENT: Thank you. Dr. McEwan...?

    MEMBER McEWAN: Thank you, Mr. President. So on page 4 of the Society's

    intervention, section 3, page 4, they discuss the erosion elements and I must confess as I was reading the consultant's report, it struck me that some of the coverings and some of the elements to a total lay person seem thin.

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    Are the criticisms there of the rate of erosion valid or has enough conservative component been put into the plan that should there be a one-in-500-year event of rainfall, for example, to ensure that the slope would remain stable?

    MR. MULDOON: Joe Muldoon for the record. I will ask Mark Liskowich from our design consultants to answer that question.

    MR. LISKOWICH: For the record Mark Liskowich.

    SRK Consulting utilized accepted engineering best practices for the development of the cover design system in order to ensure that the design meets the objectives of the approved Environmental Impact Statement.

    To that end, the criteria, the design criteria for the waste rock cover system is to ensure long-term geotechnical stability, ensure the ability for vegetation to take hold within the cover system and ensure that radiation protection or gamma emission is reduced to acceptable levels.

    The modelling used to do the design indicates that the erosion that can be expected is manageable, that there will be -- into the long term it's important to understand as well that the relationship between erosion of the cover and time is not a linear

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    function. We expect and anticipate that the majority of the erosion that would be associated with the cover would occur in the early phases of the cover system after construction, which would take place during the post-remediation monitoring phase. So there will be ample opportunities to address any erosion that exceeds acceptable limits.

    MEMBER McEWAN: And presumably the rapidity with which the vegetation is re-established would also contribute to the stability of the slope and the reduction of the erosion?

    MR. LISKOWICH: That's correct. THE PRESIDENT: So -- by the way, thank

    you for all the engineering diagrams and studies and maps. We really enjoyed looking at them, not that we understand a lot of them, but that's why we have specialists.

    I would like to hear from CNSC specialists whether, in reviewing this, you took a look at climate change, whether one in 200 is a good representation or maybe we should have gone way, way beyond that. Erosion as a function of some of the rain, downpours that we are experiencing recently are not exactly normal, so I don't know how you take all of this into account. So staff...?

    MS TADROS: So we will have Dr. Shizhong answer the technical questions.

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    With regards to the design features, both the slope and the erosion controls in place, including a robust monitoring and maintenance plan will ensure that the cover remains effective and the technical considerations, as you say, have been looked at.

    I will ask Mr. Shizhong to answer that question.

    DR. LEI: For the record my name is Shizhong Lei.

    When we reviewed the assessment, CNSC staff did look very carefully about what methodology they used, what kind of design storm they used. The most important part is their soil loss of the calculation.

    SRC used the widely acceptable approach that was described in Agriculture Canada's handbook called "Revised Universal Soil Loss for practice in Canada” and it is a result of decades of studies by the federal government, provincial governments as well as universities. It is widely used by people in Canada.

    The most important part for calculating the soil loss is -- they have many different parameters. The most important part is called the rainfall erosivity. The rainfall erosivity is determined by the total amount of precipitation in a storm event as well as the kinetic energy which is characterized by the peak 30-minute

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    intensity of the precipitation. In this case SRC used a 200 -- first of

    all, the formula is used to calculate the annual average soil loss, which for the vegetation it's established the estimate annual soil loss is about 1.5 millimetres per hundred years.

    And the storm, they used the 200-year storm. CNSC staff considered it conservative because SRC gathered climate data around the region, around Gunnar, and they picked up the most conservative number of climate data, which is from Stony Rapids, which is about 175 kilometres away from Gunnar site. The 200-year storm at Stony Rapids is actually higher than the 1000-year storm near the Gunnar site.

    THE PRESIDENT: So like all theories, it's a theory until you are executing in practice. So my question is really, if the theory doesn't deliver the result, is there any remediation that one can do after a few years if you have to augment your calculations?

    MR. WILSON: For the record, my name is Ian Wilson.

    To answer that question, because the site, after a post-remediation monitoring, is going into the ICP program, there are mechanisms within that program that would allow for not just monitoring maintenance but

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    unforeseen events as we are speaking about here. THE PRESIDENT: Thank you.

    Ms Velshi...? MEMBER VELSHI: So I mean I don't want to

    go through all the issues raised here by the Saskatchewan Environmental Society, but, staff, do you have any general comments, any here that caught your eye and said, yes, we should look at this a little closer? MS GLENN: Karine Glenn, for the record.

    I'll ask Dr. Lange to expand on that. But we did go through all of the concerns that were raised by the Saskatchewan Environmental Society. The CNSC staff's review and assessment of the plans did show that it was adequate to achieve the EA of objectives, as were accepted by the Commission in 2015. DR. LANGE: Dr. Lange for the record.

    Saskatchewan Environmental Society brought up almost all of these concerns and questions at that workshop that we had in 2016. We had an opportunity to discuss each of their concerns with the community, with the Saskatchewan Ministry of the Environment and, at that time, the community seemed appreciative of the comments and questions.

    However, I felt, along with others at the meeting, that we were able to see all of these questions

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    and concerns addressed by going forward with the proposed remediation plans. I'd say the number one point of interest was involving the communities in future monitoring activities.

    As you could see from SRC's presentation, they have shown a commitment to continue to engage communities in long-term monitoring and remediation activities.

    MEMBER VELSHI: Thank you. See, if I look at say number 4, because you've talked about erosion, contamination of Lake Athabasca, have you done any modelling of what that may look like? We expect it to decrease over time, but has there been any modelling done? MR. MULDOON: Joe Muldoon, for the record.

    I'll ask Alexey Klyashtorin, our Chief Scientist, to answer the question.

    DR. KLYASHTORIN: For the record, it's Alexey Klyashtorin.

    Well, there is a lot of information in the EIS regarding estimated loading from the site of contaminants of potential concern, COPC, from the Gunnar site to Lake Athabasca. We expect, upon completion of the remediation activities, we expect significant reduce of this loading and, therefore, we expect a significant reduce of CRPC concentrations in the water bodies immediately near

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    the site. Also we have an extended monitoring

    program, which is to be implemented during the remediation activities as well as after the remediation activities. Implementing these monitoring programs we will have all the data to be able to see how the situation in Lake Athabasca improves with time.

    Then we will compare these results with the projections done as a part of the EIS. MEMBER VELSHI: Thank you. It was really the projections I was getting at. So you've done enough modelling to know what to anticipate. So when you're monitoring, you can compare it with that? MR. KLYASHTORIN: Yes. It's a part of our EIS and it's a part of the particular design.

    THE PRESIDENT: So just to piggyback on this, and maybe I missed it in this documentation. What I was looking for is -- in fact, I actually really enjoy your charts that show the loads and where it comes from and all the flows. I think it's the first time I really understood what's going on and who's doing what to whom.

    But what I really would like to have seen is your projection about what is -- you keep sending more and more uranium and radium to the lake and to the pit and to the site. So I didn't understand how you're sending

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    more and more uranium, then how the situation will improve? In other words, over time how the improvement will be realized if you keep on loading more and more uranium?

    I was looking for your projection of what's going to happen after 10 years, 20 years, 30 years. What is your estimated actual level of uranium in the lake and the various things? So does it exist anywhere? MR. LISKOWICH: For the record, Mark Liskowich.

    In actual fact, the design of each of the covers will ultimately reduce the uranium loads to the lakes. So we're eliminating the transportation of the uranium off of the site. We're, in a sense, encapsulating it within the landfill systems and within the waste rock covers to limit the amount of uranium that actually reports to the receiving environments.

    So in the long-term, the concentrations and loadings to Lake Athabasca will be reduced significantly. THE PRESIDENT: You're reducing it, but you're not eliminating it. So the question is over time it would have been nice to see what is the steady state level you will reach somewhere? Because there will be eventually a steady state to this, is there not, or do you think it's going to be down to negligible background?

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    MR. MULDOON: Joe Muldoon, for the record. The models were completed -- and Mark,

    I'll ask you to expand -- the intent is, as Mark indicated, is to encapsulate, take the contaminants -- for instance, in the pit, is to take those sources and eliminate the avenues that they're taking to get to the lake. Those numbers are projected. They weren't all in the presentation, but we did put the ones in the pit specifically in the presentation.

    The intent is to meet the water quality objectives and their release rates that were identified as part of the environmental assessment.

    So all of the numbers and all of the projections that were made in terms of the reductions, meeting Saskatchewan water quality objectives, et cetera, all of those this remediation plan identifies the pathways and the routes that we'll take to meet all of those objectives.

    But I'll ask Mark to follow-up on that. MR. LISKOWICH: For the record, Mark Liskowich.

    I think the information that you're looking for is primarily located in Appendix B of our updated preliminary report. Essentially though, the uranium loadings will be entering into Zeemel Bay as well

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    as St. Mary's Channel will be reduced. We do have predicted levels.

    They won't be eliminated or down to zero, but they will certainly be below Canadian Drinking Water Quality Guidelines as well as Saskatchewan's Surface Water Quality Objectives. THE PRESIDENT: Staff, do you agree, number one, and did I hear that eventually we are actually aiming at actually being able to drink the water? MS TADROS: Haidy Tadros, for the record.

    So, as presented in staff's presentation, the licence does include a third hold point. When the remediation and decommissioning activities are complete it's at that time that the Saskatchewan Environmental Society will be able to comment on the proposed environmental monitoring program, that will continue with monitoring on the recovery of this site.

    Perhaps we can ask Mr. George Bihun of the Saskatchewan Environment for his comments? THE PRESIDENT: Go ahead please. MR. BIHUN: George Bihun, for the record.

    I can't recall seeing the projections there. If they're in the appendix, as Mark said, the numbers will come down and we'll see what they are in the long-term monitoring. But I've never seen the projections.

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    I think I know what you're asking for. I don't recall seeing them either myself. They may be out there, I don't recall at this moment. THE PRESIDENT: Staff, do you want to add anything to this? DR. LANGE: Yes. So the model, I agree, that they did not put the actual water quality objectives in comparison to what you're used to seeing, predictions for concentrations, in the local water bodies. However, over time, those concentrations will decrease.

    I would ask Mike Rinker to comment on the modelling for the site. But I would like to confirm that they did carryout models that calculated a reduction in loading, which ultimately did lead to a target concentration that was less than water quality objectives.

    I'll pass it to Mike Rinker to comment on those objectives. MR. RINKER: Mike Rinker, for the record.

    So I think one thing that's important is that the environment is not a closed system. So by decreasing the loading, you're not adding to a fixed system that would cause an increase in concentration.

    So high loadings right now are showing an environmental footprint in Zeemel Bay, but it's quite restricted and close to the waste rock pile where you

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    actually see a signature of those loadings. When you decrease them by a factor of 10,

    as they predicted, we do expect the concentrations to get below drinking water quality objectives and surface water quality objectives. Perhaps Dr. Goulet could add more detail to this.

    DR. GOULET: For the record, I'm Richard Goulet.

    I work for the Environmental Risk Assessment, but I'm also an Adjunct Professor at the University of Ottawa. I teach environmental remediation and environmental toxicology.

    What I'd like to add to that is basically as like the loading is reduced in the environment, you have to see the water column, plenty of particles that will capture all these contaminants, they'll settle over time in the sediments.

    So as the contaminant loading reduces with time, you'll get cleaner layers of sediments with time, and the fish and the invertebrates that will inhabit those sediments over time will be less exposed to contaminants. So, with time, they'll be safer and safer.

    So I think that's how we need to see, the situation right now. THE PRESIDENT: Okay, thank you.

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    Monsieur Harvey. MEMBER HARVEY: I think it's my turn, yes. Merci.

    My question is address to SRC. There has been many meetings, consultations, workshops during the last year. I suppose that the Saskatchewan Environmental Society they did participate to some, if not to many of those meetings.

    So I just want to have your perception, to receive a report, a memo like this, after all that with nine recommendations, are you surprised to receive that? All those things should have been discussed, I think, during those meetings. So what is your perception of such report? MR. MULDOON: Joe Muldoon, for the record.

    The first thing I'll say is I would not pretend in any way, shape or form to speak on behalf of SES. Certainly, that's their prerogative and they put this in.

    SES attended the leadership, they attended the spring meetings with us, and then were up on site in August as well. So they certainly have been participating all along with all of the major processes that we've carried out with respect to public consultation.

    I think a project of this scope and this

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    scale, it's difficult to balance best practices, and certainly we're following all of the best practices and have very good design engineers undertaking the planning for us in this regard.

    I think there's always that thought that we can always do better and we'd like that extra measure. So I think that's probably where some of this comes from. I think where we have this covered, I think where we've got it well-covered, is that, number one is we'll continue to consult all of our numbers and all of our data's going to be open, CNSC staff are involved obviously with that as well.

    We have the long-term monitoring. Communities, including SES, will be involved with that. We have the ICP that in the very long-term as the program enters into institutional controls. Then if the numbers aren't coming down as projected, there's the opportunity to then go in and fix it.

    Our intent, obviously, is from a costing side, is to take the approach now, to undertake all of the work that needs to be required and ensure that we meet the targets that we've laid out that are based on solid modelling based on the science that we have.

    We certainly don't want to have to go back in and do any major work, and that's why I think we've been

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    very careful in the way that we're going to both design and implement that design.

    So I think we have enough opportunities to ensure that we're able to meet the targets. I'm not surprised and there's absolutely nothing wrong with always being pushed to the limit with respect to our design and where it can to, and we'll continue to do that, understanding that we're also operating with public money and we have to ensure that we use it effectively and efficiently. MEMBER HARVEY: That is very nice to see it like that, yes, to be pushed. THE PRESIDENT: Thank you. Monsieur Tolgyesi. MEMBER TOLGYESI: There was a note on page 5 where, according to Saskatchewan Environmental Society, there is a kind of mix-up. When you're talking about pH-impacted rock and contaminated rock, I suppose the pH-impacted rock is rock which has acid generation potential or is acid generating? While as contaminated rock, it's contaminated by other elements, other contaminants?

    I'm sorry, was I clear? No? Yes? Okay. So it is good, my perception, or is it

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    wrong? MR. MULDOON: I'm going to ask Alexey Klyashtorin to deal with the pH-rock and where it's going and the impacts. MR. KLYASHTORIN: For the record, it's Alexey Klyashtorin.

    When we are talking about pH-impacted rocks we are mainly talking about the acid plant footprint. The rocks there are not acid-generating by themselves, but mainly because as they were contaminated by elemental sulphur and some products of its oxygenation and weathering in time.

    So that's why we do not call the rocks by themselves acid-generating, but the material which is rock mixed with this elemental sulphur and its products has very low pH. So that's why we call it pH-impacted. For this area, I mean acid plant footprint, we do not anticipate any other contaminants, but low pH.

    MEMBER TOLGYESI: So when you say low pH, it's acid?

    MR. KLYASHTORIN: Yes, it's very diluted sulphuric acid, that's how we see this.

    MEMBER TOLGYESI: You expect, if I understand well, you will store or pile this acid-affected rock on the tailings --

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    MR. KLYASHTORIN: Yes, we incorporate it as a tailings cover.

    MEMBER TOLGYESI: -- and eventually for the cover? Okay.

    THE PRESIDENT: Thank you. Dr. McEwan. MEMBER McEWAN: Thank you, Mr. President.

    The one other thing that struck me as I looked at this was under miscellaneous questions, (e), which is on page 5. In particular, looking at the 3D rendered image you did of the whole mine pit, if I remember it correctly, the bottom of the shaft is about 600 metres. So the hole of the shaft is flooded down to the 600-metre level. Therefore, there will be a uranium concentration through the hole of the 600 metres or, as they say, is there a relative concentration that will be higher up?

    Is there any loss of water from the lower levels of the pit or is it fixed once we get down there? If there is loss, does that create a future potential risk to the lake? MR. KLYASHTORIN: For the record, it's Alexey Klyashtorin.

    At the moment, we do not have any evidence of active water exchange between the flooded mine working and upper parts of the water column in the flooded pit.

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    Moreover, we have a lot of evidence of the existence of the so-called chemocline at the depth of approximately 70 metres in the pit. What is interesting, that uranium concentrations below the chemocline, below the depths of 65-70 metres in the pit are lower than uranium concentrations above the chemocline and in the surface part of the water column.

    That's why we have no concerns -- well, that's why we have no concerns about any potential for the deep water from the ground mine working coming to the surface of the pit, because its water exchange very likely doesn't exist, the chemocline is the evidence.

    Second, even if we imagine this may happen, then the concentrations in the bottom of the pit is lower than the actual concentrations in the upper part of the pit, so it will not be a problem. THE PRESIDENT: Okay, I'll bite. Explain to me -- I thought uranium sinks? Why is the upper part more concentrated than the lower part? Please explain to me the physics here. MR. KLYASHTORIN: Yes. Well, it's not physics, it's chemistry, I believe. --- Laughter / Rires

    THE PRESIDENT: That explains why I don't understand.

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    MR. KLYASHTORIN: In my opinion, it's mainly because of the lower oxygen concentration in the deeper part of the pit, so uranium has less opportunities to be in its 6 oxidized form, that's called Uranium(6), which is known to be very well soluble, and much more soluble than the so-called uranium(4) form.

    So the ratio between two forms of uranium is different in the upper part, more oxygenated, and lower part less oxygenated. That's why uranium concentration in the bottom of the pit is lower than in the upper. THE PRESIDENT: Thank you for that.

    Ms Velshi. Monsieur Harvey. MEMBER HARVEY: Quick question on page 19 of your -- or it's, no, it's not in the... Sorry, not yet. THE PRESIDENT: Okay. Anybody else?

    So the only thing is that, as staff already said, there will be an opportunity for such interveners in fact to take a look at the annual reports that shows about progress here and comment and intervene on anything that requires further discussion.

    So thank you.

  • CMD 16-H6.3 Written submission from Prince Albert Grand Council THE PRESIDENT: I'd like to move on to the next submission, which is from Prince Albert Grand Council, as outlined in CMD 16-H6.3. Any comments? Monsieur Harvey? MEMBER HARVEY: Page 2, at the top of the page, there is an expectation that much of the work that will be done at the Gunnar site will be done by the Indian Nations, Indian People. I saw that there is already work done by the natives, and you think that will continue and a good proportion of the work will be done by those resident people? MR. WILSON: For the record, Ian Wilson. The answer is yes. Part of our procurement process and part of the contractual obligations, that we hire for any of the prime contractors that will do this work are very succinct local labour inclusion, local equipment inclusion, and a per cent of the total value of their portion of the work left in the communities to the point where we have both bonuses and penalties should they not meet that. MEMBER HARVEY: Thank you.

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    THE PRESIDENT: Dr. McEwan? MEMBER McEWAN: So on the first full paragraph on page 2, is there indeed a real risk of a short-term disruption to the trappers and fishermen by the activities on the site or can they be constrained so that that risk actually isn't real? MR. WILSON: For the record, Ian Wilson.

    Whether there is either a real or perceived risk, part of what we do is talk to the owners of that trapline to make sure that they understand what the project entails, to see if there's any risk to their trap lines and adjust or compensate in anyway. MR. MULDOON: Joe Muldoon, for the record.

    There likely will be some level of short-term disruption. As Ian has mentioned, we've already started discussions with any of those impacted with respect to trapping. I just wanted to make sure that we have that covered. THE PRESIDENT: Ms Velshi. MEMBER VELSHI: So I just want confirmation from both of you that as far as this intervention's concerned, they show no concerns with your remediation plans as presented, correct? MR. MULDOON: Joe Muldoon for the record.

    Again, I want to be very careful in terms

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    of -- we've gone out and done the consultations, we've explained everything and have been very open and transparent in all of our planning and in our implementation. We've done everything in our power to ensure that we are, from an economic side and a socioeconomic side, that we're working with the communities.

    So we've gotten very good support. I won't pretend to say that there's not going to be somebody somewhere out there -- and certainly we've heard from, you know, those that aren't necessarily comfortable with every approach that we take and every step that we take. So I don't think I could say here honest that, you know, there aren't absolutely no concerns.

    But I believe that we've, in working with CNSC staff and with the meetings that we've done, that we've actually -- we've very much gone that extra mile. And that the vast majority of those that we've interacted with are comfortable wit and, most importantly, understand what we're doing and why, and they're supporting the approaches that we're taking. THE PRESIDENT: In fact, maybe staff can augment. My understanding was that we got a lot of representation to get on with it, to get the work started here.

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    MS GLENN: Kairine Glenn, for the record. I'll pass the question back to Mr. Levine,

    who's with our Aboriginal consultation group and attended the workshops and toured the communities.

    But I'll begin by saying that should there be any concerns going forward by the community, the Gunnar project will be reported on annually by CNSC staff beginning in December of this year as part of the regulatory oversight report, and this will be the plan going forward, and written interventions will be solicited and participant funding is being offered. MR. LEVINE: Adam Levine, for the record.

    So you're right, Dr. Binder, one of the main concerns was wanting for the projects to actually get started, as you saw in the video that SRC presented, that many of the community representatives and leaders really want to see this cleaned up, because this has been going on for many many years now and it's been a long process and it's been an important process for them to be a part of.

    So we've had a lot of great discussions, the workshops have been very helpful in getting out those concerns and educating both ourselves and the communities about the concerns and about the plans that the SRC have to remediate this site.

    I think we've gotten to a place now where

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    everyone's comfortable with the information that's been provided, with the consultation that has been done, and I think everyone's ready to move forward.

    As has been mentioned already, we're going to continue to work with the communities, we're going up there again in December or January sometime this winter with the SRC to do the annual tour of the Athabasca communities, and we'll continue to engage them and make sure that they're involved. And any concerns that are raised, we'll be there to help address them.

    But it's been a very fulsome and thorough engagement process to date, and I think that many of those concerns have been addressed. THE PRESIDENT: Thank you.

    Any other questions? MEMBER HARVEY: A quick one. THE PRESIDENT: Monsieur Harvey. MEMBER HARVEY: My question goes to the President. At the end of the last paragraph, "We look forward to meeting with CNSC President Dr. Binder." So do you have a date? THE PRESIDENT: I'm always available and happy to meet with whoever wants to meet with me. MEMBER HARVEY: There's no date. You like dates?

  • --- Laughter / Rires THE PRESIDENT: Well, they can set-up a date anytime. I think we are planning to go to La Ronge. I don't know how far that is, but it may be an opportunity to meet. Okay. So I'd like now to open up the questions by commissioners on the two presentations by SRC and staff. But I'm just wondering, do we need a 10-minute break? Okay. We'll come back at 3:05. Thank you. --- Upon recessing at 2:54 p.m. /

    Suspension à 14 h 54 --- Upon resuming at 3:09 p.m. /

    Reprise à 15 h 09 THE PRESIDENT: Okay, we are back and we're going to start the question period avec M. Tolgyesi. MEMBRE TOLGYESI : Merci, Monsieur le Président. When you're looking at a report and make any report, the design report, the site survey is not completed and the design is not completed. Should it be --staff, should it be completed prior to your approved -- you

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  • accept this proposal? DR. LANGE: Dr. Lange, for the record. I'm inferring that you are talking about how the detailed design plans have not yet been reviewed by staff. MEMBER TOLGYESI: Yeah. DR. LANGE: Okay. For this project the SRC required -- and I'll ask SRC to confirm this after --the SRC will be hiring a contractor if they get permission to proceed to Phase 2. So CNSC required SRC to demonstrate that they are able to fulfil the EA objectives through their remediation plans, that CNSC requirements are met and, as well, that they are going to carry out remediation plans in line with good industry practice and that will, staff is recommending, enable them to move on with remediation of the remainder of the site. And at that time they will hire a contractor to develop the design -- the detailed design plans. That said, CNSC staff is going to review those detailed design plans and that is a condition in the licence condition handbook that staff approve those design plans and ensure they are still consistent with the objectives. And I'll ask SRC to talk about their contractor.

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    MR. WILSON: For the record, Ian Wilson. What Dr. Lange had mentioned is actually

    the process that we are using where we integrate both the prime contractor that does the implementation as well as the present and future design contract for the engineering design through the process. Throughout the process, the entire process, we'll be looking for CNSC as well as Ministry of Environment and other regulatory bodies to continue to, I guess, view and review any engineering designs as well as any implementation plans and any management systems associated with it.

    THE PRESIDENT: Just bring us up to speed. We are doing -- CNSC released in last September -- allowed you to get work going. Is there any work going now, because I still hear of selecting of contractor? So is there anything has been done and is work already started onsite?

    MR. WILSON: For the record, Ian Wilson. Our hold point for the tailings was

    released. This summer we went out through a public procurement process and we have selected a prime contractor to facilitate the tailings work as per the signed design. We are actually starting and kicking off, doing some preliminary work this season with 2017 with the majority of their fleet, mobilizing and starting the tailings work over

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    the next four to five years. THE PRESIDENT: So you have got all the

    equipment there already or do you still need kind of a harsh winter to allow you to get all the equipment?

    MR. WILSON: For the record, Ian Wilson. What we did over the last ice road is we

    took some of the local pieces of equipment with owners that agreed to bring them over on the ice road. It did two things. It allowed local integration of equipment owners into the project but it also allowed SRC and the prime contractor that's coming in to have a small fleet of equipment to start some preparatory work with the understanding that they will bring other larger implements over on this forthcoming ice road season.

    MR. MULDOON: Joe Muldoon, for the record. And that work is beginning now. That

    contract has been given and the contractor is going to be up on site before the end of the month doing work onsite, road building and burrow activities and so on. So we are doing work in 2016. Obviously, as well as the contractor then has the opportunity to bring more equipment on during this winter season on the ice road.

    THE PRESIDENT: Thank you. Dr. McEwan...?

    MEMBER McEWAN: Thank you, Mr. President.

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    Again this is really just trying to understand. So in 5.1.3 of the updated preliminary design you say that viable asbestos is double bagged -- 26.

    THE PRESIDENT: Of SRC? MEMBER McEWAN: Of SRC's first document. How robust is the double bagging over a

    100-year design plan for this state? Is it likely to remain intact? If it doesn't remain intact and it's buried at the bottom of the landfill can it be mobilized out of the landfill somewhere else?

    MR. WILSON: For the record, Ian Wilson. The design allows for the asbestos to be

    underlying multiple layers of other materials per the landfill design. The design for, I guess, managing asbestos is exactly what any municipal landfill would do and the same concept is going to apply here.

    THE PRESIDENT: Thank you. Ms. Velshi...?

    MEMBER VELSHI: Thank you. So I want to commend you on your exemplary Aboriginal and public engagement activities. I found the video to be very helpful because it gave reassurance that you had public support. You haven't got many interventions from them in spite of all those activities. So well done in having that 3-D model of the underground workings. It really helped

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    and I can see how it would be helpful. So and compliments to staff as well for your engagement activities.

    Slide -- now, as a quick question, on slide number 19 on the estimated uranium loadings to the Gunnar open pit, as I look at the different areas, you know something that just sort of hit me, was why for the EWRP is the reduction so much less than for the other ones where it's 90 percent or so and it's only 34 percent that you are expecting there? So it's maybe time for another short chemistry lesson. --- Pause

    MR. LISKOWICH: For the record, Mark Liskowich.

    Sorry for the confusion in formulating our answer here, but I believe the difference in the reductions is largely because the load from the waste rock currently is focused on the channel that we are going to re-establish. The waste rock -- seat one in the waste rock pile is currently the significant contributor to the loads coming from the waste rock pile. By re-establishing the channel that source will be removed which is the majority of the uranium loads. The remaining loads will be from the waste rock that is remaining in-situ which will be covered.

    MEMBER VELSHI: So the remaining rock in-situ, that production you expect to be in the 80 or 90

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    percent then? MR. LISKOWICH: The remaining -- the 34

    percent of uranium that will continue from the waste rock will report to the pit. The reduction from the waste rock will be realized through the channel.

    MR. MULDOON: Joe Muldoon, for the record. I think if -- and correct me, Mark, if I

    am wrong. The waste rock, most of the contaminants from the waste rock report to Zeemel Bay. There is only a small proportion that reports to the pit. So therefore, the reduction is much smaller relative to when we open up that stream that's going to significantly reduce but it reports the other way to Zeemel Bay.

    THE PRESIDENT: Just I think -- sorry, staff?

    DR. LANGE: Dr. Lange for the record. I just wanted to add that in reviewing

    these estimates, they are very conservative in nature. So 34 percent upon review, upon our review is actually greater than 34 percent. However, these are the conservative percentages that are presented here. So I just wanted to note that.

    And I agree with your earlier comment. It would be good to show a concentration for that reduction because the concentrations in that area are actually fairly

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    low to begin with. So in addition to a percentage, in the future we will put a concentration in there.

    THE PRESIDENT: Just a general question. On a couple of the tables here you have what the preliminary design -- where and then the current understanding. What I want to know is what changed? Some of the change is quite significant but how did you come up to the preliminary and then you updated them and it changed quite remarkably, actually? Anybody want to give me kind of a quick overview? --- Pause

    MR. LISKOWICH: For the record, Mark Liskowich.

    Primarily the difference in the numbers is a reflection of additional data that was gathered over the course of the last year or two. There was a hydrogeological study that was completed that informed us a little bit more from the original assumptions that were made. So there is ongoing data that has been factored into the calculations and into the predictions to give us more certainty and more clarity.

    THE PRESIDENT: Okay. So you expect these to be a stable now estimate? You don't need more data to collect to verify further?

    MR. LISKOWICH: No, we don't believe so.

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    THE PRESIDENT: Okay, thank you. MEMBER HARVEY: I'm always here.

    --- Laughter / Rires MEMBER HARVEY: One of the comments from

    the workshop of April 26 was the design to the mine pit --the mine pit water would be drained and treated. I understand that this is not an option and that the amelioration of the quality of the water will come from the fact that the contamination will be stopped by the --coming from the tailings.

    So I come back to your presentation. Page 21 you say the objective is to reduce human health risks and reduce ecological risks. So I would like to just to compare what are the current risks? What are you trying to ameliorate there?

    My question -- my question goes to, well, to both. Yeah, so I don't know who wants to take the lead.

    DR. LANGE: Perhaps to talk about the current risks most important to the community would be the fish. And I would ask Dr. Steve Mihok to talk about the risk of fish consumption at that site and from there we can talk about other risks.

    Would that be all right? MEMBER HARVEY: Are you talking of the

    risk in the pit, the water in the pit?

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    DR. LANGE: Fishing anywhere around the site.

    MEMBER HARVEY: Around the site but I'm just talking of the pit itself.

    DR. LANGE: Oh, okay. MEMBER HARVEY: No, just the pit because

    in the table on page 20 that was under the open pit. So I'm just -- what are you trying to ameliorate for the pit itself? What is the current problem because the water quality of the pit will probably ameliorate by a natural process if the contamination is reduced? So what is the risk now and what will be -- what is your expectation for the future?

    MR. MULDOON: Joe Muldoon, for the record.